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<br />There are legitimate concerns to deal with. Having several recovery <br />plans for the endangered fish fragments recovery activities for the species. <br />The criteria for downlisting and delisting has become more restrictive with <br />the update of the Colorado squawfish plan requiring the San Juan River and an <br />additional population in the Lower Basin to be recovered. <br /> <br />We are concerned that the requirements of the Endangered Species Act for <br />consultation, and the direction presently being pursued in the biological <br />opinions, may affect Reclamation's primary responsibility for water <br />conservation storage and flood control. Some of you also feel that these <br />measures may violate the "Law of the River." The Fish and Wildlife Service is <br />holding to the hypothesis that "natural flows" are better for the endangered <br />fish and that operations that mimic the natural hydrograph is the primary <br />reasonable and prudent alternative for recovery of the species. <br /> <br />You frequently hear the term "mimic the natural hydrograph" used in <br />these discussions. Without defining that term, you may begin to wonder just <br />what the role or function of the dams are. We define "mimic" as the shaDe of <br />the flows. They follow the historic natural flows, but do not necessarily <br />duplicate the volumes of the historic flows. Rather, it is a release pattern <br />recreating the seasonal flows and is responsive to the current year's <br />hydrology. <br /> <br />Each of the mainstem dams in the upper basin of the Colorado River are <br />under some state of consultation. All indications are that the reasonable and <br />prudent alternatives for all units will be similar. <br /> <br />At Flaming Gorge, the Service's Final Draft Biological Opinion, issued <br />February 12 of this year, calls for low stable flows in the late summer, fall, <br />and winter and high flows in the spring. Historically, we have stored water <br />during the heavy spring snowmelt period and made large volume releases in the <br />summer and winter. Included in the releases were fluctuations to meet power <br />demands. <br /> <br />At the Aspinall Unit, we are initiating research that will lead to a <br />Biological Opinion in 5 years. A preliminary report done by the Service <br />centers on how the flows have been altered from the natural conditions. We <br />have been requested to follow a natural hydrograph during the 5-year research <br />period to study possible biological responses to the fish community. The <br />approach of this research is different than in the past wherein the Service <br />wants to see operational changes up front based on the information and <br />hypothesis generated from other biological opinions. <br /> <br />At Navajo Dam, Reclamation has agreed, under consultation to follow the <br />natural hydrograph for a 7-year research period and on a long-term basis based <br />upon the research results. <br /> <br />What are the impacts of such operational changes? To recreate the <br />natural flow conditions we provide low, stable flows throughout the summer, <br />fall and winter and high releases in the spring. That's generally opposite of <br />historic reservoir operations. Such releases may be injurious to the primary <br />purposes of conservation and storage. They may cause a significant drawdown <br /> <br />7 <br />